Surgical excision of a subcutaneous soft tissue tumor of the foot or toe measuring less than 1.5 cm in its greatest dimension.

Verified May 8, 2026 · 7 sources ↓

Medicare: $382.11
Work RVU: 3.86
Global, days: 90
Region: Foot & ankle

Drawn from CMSAAPCMdclarityKzanowAacpm

Documentation requirements

What must appear in the operative or office note to support the claim.

Source · Editorial brief grounded in 7 cited references ↓

Measured size of the resected specimen documented in the operative note — must be less than 1.5 cm to support 28043 over 28039
Depth of tumor explicitly stated as subcutaneous; 'soft tissue mass' alone is insufficient to distinguish from subfascial codes 28045 or 28041
Operative note must identify the anatomical site on the foot or toe, not just 'foot' — laterality (left vs. right) required for modifier assignment
Pathology report correlating with the excised specimen, confirming tumor type and margins where applicable
Indication for surgery documented in the medical record, including symptom duration, failed conservative treatment if applicable, and clinical or imaging findings supporting excision

Applicable modifiers

Modifiers commonly billed with this code.

Source · AMA CPT modifier descriptors · CMS NCCI Policy Manual

22 Increased complexity 24 Unrelated E/M during global 51 Multiple procedures 58 Staged or related 59 Distinct service 76 Repeat, same physician 77 Repeat, another physician 78 Unplanned return — related 79 Unrelated during global LT Left side RT Right side XS Separate structure

What this code covers

Source · Editorial summary grounded in 7 cited references ↓

CPT 28043 covers removal of a subcutaneous soft tissue tumor of the foot or toe when the resected specimen is less than 1.5 cm. The key size threshold separates this code from 28039, which applies when the resected area is 1.5 cm or greater. Depth matters equally: 28043 is strictly subcutaneous. Deep or subfascial tumors — including intramuscular lesions — go to 28045 (less than 1.5 cm) or 28041 (1.5 cm or greater), regardless of measured size.

Do not report benign skin lesion excision codes (the 11400 series) for a subcutaneous foot tumor. The correct code is 28043 even if the operative report uses language like 'benign excision.' Skin lesion codes describe epidermal and dermal lesions; 28043 describes excision of a mass arising below the dermis in the subcutaneous layer of the foot or toe.

The code carries a 90-day global period. Any related E/M services, wound checks, or dressing changes during that window are bundled. Unrelated E/M visits require modifier 24. If the pathology comes back malignant and a wider re-excision is planned, use modifier 58 to reset the global clock. Laterality modifiers LT and RT are standard; some commercial payers — notably BCBS — have flagged claims carrying only an anatomical modifier without a required HCPCS laterality modifier, so confirm payer-specific modifier requirements before submission.

RVU & reimbursement

Component RVUs and Medicare national rate. Actual payment varies by GPCI locality.

Source · CMS Physician Fee Schedule, RVU26A · January 2026

Work RVU vs. total RVU

The work RVU (3.86) is the surgeon's own effort — the figure physician pay and productivity targets are built on. The total RVU (11.44) adds practice overhead and malpractice, and is what drives the Medicare payment below.

Work RVU	3.86
Practice expense RVU	7.18
Malpractice RVU	0.4
Total RVU	11.44
Medicare national rate	$382.11
Global period	90 days

Payment by site of service

Medicare pays different rates by setting. HOPD typically pays substantially more than ASC for the same procedure.

Source · CMS OPPS Addendum B·ASC HCPCS payment rates·2026

Setting	Medicare rate (national)
Office (PFS non-facility) Procedure performed in physician's office	$382.11
HOPD (APC 5072) Hospital outpatient department	$1,687.37
ASC (PI G2) Ambulatory surgical center (freestanding)	$742.04

Common denial reasons

The recurring reasons claims for CPT 28043 get rejected.

Source · Editorial brief grounded in CMS NCCI edits, AAOS coding appeals, and cited references ↓

Wrong code family: billing 11422 or similar benign skin lesion excision codes instead of 28043 for a subcutaneous foot tumor
Size threshold mismatch: operative note documents a resected specimen at 1.5 cm or greater, which maps to 28039, not 28043
Depth not documented: payer downcodes or denies when the operative note fails to specify subcutaneous versus subfascial depth
Missing or incorrect laterality modifier: some payers, including certain BCBS plans, require both an anatomical modifier and a HCPCS laterality modifier (LT/RT) on the same claim line
Global period conflict: related E/M or wound care billed within the 90-day global without modifier 24, triggering a bundling denial

Frequently asked questions

Source · Generated from the editorial pipeline, verified against 7 cited references ↓

01Can I bill 11422 for a subcutaneous foot tumor measuring 1.2 cm?

No. Benign skin lesion excision codes (11400 series) apply to epidermal and dermal lesions. A subcutaneous tumor of the foot or toe is correctly reported with 28043, regardless of size, as long as the specimen is under 1.5 cm.

02What code applies if the tumor is subfascial or intramuscular rather than subcutaneous?

Use 28045 for a subfascial foot or toe tumor under 1.5 cm, or 28041 if it is 1.5 cm or greater. Depth documented in the operative note drives the code selection — subcutaneous vs. subfascial is not interchangeable.

03What happens if the resected specimen comes in at exactly 1.5 cm?

28039 applies at 1.5 cm or greater. The 28043 threshold is strictly less than 1.5 cm. Document the measured size precisely; rounding ambiguity will not hold up in an audit.

04How should I bill a second tumor excision on the same foot during the same session?

Report 28043 for the first lesion, then append modifier 59 (or XS for a separate anatomical site) to the second 28043. Modifier 51 may also be appropriate if additional distinct procedures are performed. Confirm NCCI edits before submission.

05The patient needs a wider re-excision after pathology shows malignancy. How do I bill during the global period?

Use modifier 58 to indicate a staged or related procedure planned after the initial excision. This resets the 90-day global clock. Do not use modifier 78, which is reserved for unplanned returns to the OR for a complication-related procedure.

06Do I need both an anatomical modifier and LT/RT on the claim?

For Medicare, LT or RT alone is typically sufficient. Some commercial payers — BCBS plans in particular — have issued denials when only one type of laterality modifier is present. Verify payer-specific modifier requirements in your contracts before defaulting to a single modifier.

Sources & references

Editorial content was developed using the following public sources. Last verified May 8, 2026.

Mira Scribe

Mira's AI scribe captures tumor location (foot vs. toe, specific digit if applicable), laterality, depth layer (subcutaneous confirmed), and measured size of the resected specimen directly from dictation. This prevents the most common 28043 denial: a note that says 'soft tissue mass excised' without documenting sub-1.5 cm size and subcutaneous depth — the two fields auditors check first to distinguish 28043 from 28039, 28041, and 28045.

See how Mira captures CPT 28043 documentation